The GSE-less Mortgage Industry
- 1. The
Summit Point
Group
The GSE-less Mortgage Industry
Anticipating (and Adjusting to) a Life without Fannie and Freddie
After months of speculation it now appears clear that Fannie Mae and Freddie Mac will cease
to exist at some point over the next few years. The beginning impacts of the dissolution of
the companies are likely to be felt by the industry much sooner. While much of the news
and conversation has been focused on portfolio sizes, loan limits, securitization, and interest
rates, little has yet been said about the operational impacts on the mortgage industry that
will result from the demise of the GSEs. Possibly forgotten in the discourse are the policies,
requirements, guidelines, standards and technology that Fannie Mae and Freddie Mac have
“provided” to the industry for at least the last generation.
While months of hearings, legislation, and rule-making will determine the final destinies of
Fannie Mae and Freddie Mac, with the drama likely playing out over a period of months or
years, changes are already being discussed within Congress and by the GSE’s regulator that
will have near term impacts on the industry. These near term changes, combined with the
unfolding of tens or hundreds of others, will not only change the secondary markets, but
ultimately how business is done.
While it is still impossible to identify all of the changes that will come about due to the
transformation of the industry, through early assessments it is possible to begin to identify
areas where these changes can have the greatest operational impact on the mortgage
industry. These are not topics that will appear in the news, but will still have significant
financial impact, require organizational change, and may change many aspects of how the
business is done and supported today. Looking from the top down, identifying macro
changes is relatively easy; new investors, increased role for the MI companies, innovation in
securitization, etc., etc., etc. But a view from the bottom up reveals a world of change that
may (will) evolve as the GSEs exit the market.
With just a high-level glance at some of the structure and services that the GSEs currently
provide to the industry, we can begin to evaluate how the withdrawal or absence of the
GSEs will impact or otherwise affect industry participants and start to draw conclusions and
plan for operating (and possibly surviving) in a GSE-less world.
Conforming Loan Standards
Early proposals call for decreases in conforming loan limits and the ratcheting up of
guaranty fees. These changes will signal the start of a gradual withdrawal of the
GSEs from the loan purchase and securitization markets through limitation of loans
that may be purchased and the opening of the market to competitors through
elimination of buried credit subsidies that are offered through lower guaranty fees.
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Business Impact: While the complete exit of the GSEs from the market may take
years, these early first steps will immediately reduce the scope of loans purchased
and securitized by the GSEs while providing incentive to other secondary players to
enter the markets. MI companies will likely regain market and influence previously
lost to FHA and recession-driven GSE loan programs.
Operational Impacts: As the GSEs withdraw from the secondary market, originating
lenders will be required to establish or renew relationships with other secondary
market players. Existing and new secondary participants will be required to ramp up
operations for new business. Areas of impact will likely include:
Underwriting requirements and standards
Processes and procedures related to loan processing, closing, and delivery
Loan program eligibility and pricing structures
Risk sharing structures; regained MI influence
Data requirements; new and changed
Commentary: The early and (hopefully) measured withdrawal of the GSEs from the
market will begin to unveil areas where their influence drove and often dictated
standards and methods. At a minimum, loans that are outside of GSE eligibility will
begin to fall under the guidelines established by other secondary market participants.
Can the 30-year mortgage be in jeopardy?
Selling Guidelines
While related to the above topic, the influence of the thousand pages-plus selling
guides of Fannie Mae and Freddie Mac have gone far beyond contract terms and
eligibility guidelines in defining how the industry underwrites and otherwise
processes mortgages. These guides are today the typical foundation for lenders’
processes, procedures, guidelines, compliance and credit policy. GSE LLPA tables
often define the risk-based pricing structures that are in use across the industry.
Business Impact: Though immediate business impact is not likely outside of the
reduced GSE eligibility limits, longer term questions surely exist with regards to
selling standards and processes. Will this coming gap be filled by greater government
regulation (local, state, federal) or a new association of secondary players; or will it
result in a highly fragmented market, with each secondary participant dictating their
own set of guidelines?
Operational Impacts: Over time, one can only guess as to what the ultimate impact
on selling guide standards and methods will be in a world without the GSEs. Absent
the near centralization of guidelines afforded under the GSEs, the industry will be
open to great influence in this area. Similar to the above topic, areas of impact will
include:
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Underwriting requirements and standards
Processes and procedures related to loan processing, closing, and delivery
Loan program eligibility and pricing structures
Data requirements; new and changed
Commentary: Depending upon how the secondary market evolves as the GSEs exit,
this single aspect could have the greatest impact on how business is done. Will
governmental entities step in to dictate standards and guidelines? Will secondary
market players align, or will certain entities use the gap created by the GSE exit to
establish guidelines and standards designed to enhance competitive position? Will
selling originators be forced to juggle guidelines and standards, adopt worst-case
methods, or align on a single secondary player? And how will technology influence
this aspect of the industry; positioning large secondary players, or alternatively
enabling the nimble seller?
Technology
Somewhat understated as part of the dialogue related to the passing of the GSEs, the
technological impacts on the mortgage industry stand to be substantial. While surely
not overlooked, the influence of Fannie Mae and Freddie Mac on technology has been
sweeping. Areas of influence (among others) include data and transactional
standards, delivery and reporting methods, servicing requirements, and let’s not
forget, automated underwriting. There is not a participant in the mortgage industry
(and some outside of the industry) that is not following some standard or method, or
using technology that is vended or supported by Fannie Mae and/or Freddie Mac.
Over the past twenty years, the GSEs have invested hundreds of millions of dollars to
build extensive systems, as well as to inspire or otherwise influence many hundreds
of millions of dollars invested by others – customers, vendors, and service providers.
Business Impact: The business impact of the coming technological transformation of
the mortgage industry is likely being recognized and evaluated (if not felt) already.
Aspiring secondary market participants will likely be required to invest heavily in
technology to take a place in the new market. Smaller participants (sellers) will
need to evaluate their options for maintaining independence or aligning with larger
secondary players, and possibly just staying viable as mortgage market participants.
Operational Impacts: The operational impacts related to technology and the
withdrawal of the GSEs from the mortgage market will be addressed in different ways
by different market entities. As mentioned above, new and existing secondary
players will need to invest heavily in know-how, methods and technology to stay
competitive in the secondary market. Smaller sellers will be required to assess and
determine their place in the market. Software vendors and service providers will
provide new solutions to address new challenges and opportunities. In all cases,
technology change can be anticipated and will be required to address the following:
Automated Underwriting (including eligibility and pricing)
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Changes in mortgage forms and documentation
Data requirements and transactional standards that emerge, based upon
the diversity of participants
Changes in loan program requirements and structures
Increased data and reporting requirements driven by government rule
making and legislation
General need for flexibility and configurability to address periods of rapid
change
Commentary: There is no need to look beyond the current origination procedures
and processes to appreciate the influence of the GSEs on the mortgage industry of
today. The 1003/URLA is a form that was created and is maintained by Fannie Mae
and Freddie Mac. The vast majority of mortgages originated are submitted to
Desktop Underwriter or Loan Prospector before being just a few hours (or less) “old.”
Beyond these two examples, the list of influence continues to include processing,
delivery, servicing, and loss mitigation/liquidation activities. While certain
requirements and standards will continue to be maintained for many months or even
years while the GSEs are dismantled, other areas of technology already beg for
immediate attention and possible replacement today - before it is too late.
The challenges of the last few years have had a dramatic impact on the mortgage industry,
driving a rapid succession of changes that now includes the dismantling of Fannie Mae and
Freddie Mac. Unlike the demise of any other bank or lender in the industry, the exit of the
GSEs will bring about significant changes in how the mortgage business is conducted,
creating a unique set of challenges and opportunities for mortgage industry participants.
While one can only speculate as to how this play will end, there has already been enough
exposed in the first act to point to the need for industry participants to begin planning (and
acting) for a future that does not include Fannie Mae and Freddie Mac. Operational planning
that includes investment in new methods, processes and technology can create or otherwise
enable the needed flexibilities that will be required to remain competitive and viable in an
industry that is poised for a period of rapid change.
About the author: David Coleman is Managing Director of The Summit Point Group, a strategic management
and technology consulting firm. He is an accomplished mortgage industry executive with more than 20 years
of demonstrated success developing and executing strategies for major business and technology initiatives,
turn-around transitions, and operational start-ups. Prior to founding The Summit Point Group, David served
as Vice President of Technology at Fannie Mae, where he led strategic business and technology planning. His
accomplishments while at Fannie Mae included the development and roll-out of Desktop Underwriter.
davidcoleman@thesummitpointgroup.com
Copyright © 2011 The Summit Point Group www.TheSummitPointGroup.com